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January 30, 2020

The Honorable Russell T. Vought
Acting Director
United States Office of Management and Budget
725 17th Street, NW
Washington, DC 20503

The Honorable Alex M. Azar II
United States Department of Health and Human Services
200 Independence Avenue, SW
Washington, DC 20201

Dear Acting Director Vought and Secretary Azar, 

Proposed regulations issued last year from the Department of Health and Human Services would revolutionize the exchange of medical records—ensuring that patients can access their own data and fostering innovation in the tools available to health care providers. However, those rules—proposed by the Office of the National Coordinator for Health Information Technology (ONC) and the Centers for Medicare & Medicaid Services (CMS)—remain under review by the Office of Management and Budget (OMB). We strongly urge the administration to finalize these rules without further delay to help ensure that patients, providers, and clinicians have more complete health information wherever and whenever they need it. 

ONC’s proposed rule implements an integral component of the 21st Century Cures Act (Cures) to encourage all stakeholders to use modern tools to exchange data. In Cures, Congress directed ONC to develop new criteria for EHRs to make patients’ medical records available via application programming interfaces (APIs), which are software tools that allow systems to more easily communicate with one another much like how many websites share information. CMS is proposing that Medicare and Medicaid plans also make claims information available to their members using APIs. 

APIs can make it easier for patients to obtain their data on personal devices, such as smartphones or tablets, and aggregate their own records from many different health care providers and health plans to be able to take greater ownership of their care. Clinicians could also use APIs to implement new decision support tools that provide new capabilities, such as programs that help select the most appropriate medication or create a targeted treatment plan. Standard APIs can even help foster greater data exchange among health care providers and with health plans by enabling them to receive targeted patient-specific information. 

Given these benefits, ONC’s proposed rule generated significant support from a wide variety of groups— including EHR developers, health care providers, and public health organizations. By finalizing the rules, the administration can provide patients, technology developers, and health care providers with clarity on API requirements so that these stakeholders can continue to work with government on private sector and policy solutions to increase the privacy and security of data exchange no matter where the data reside. 

We urge you to support ONC and CMS’ approach and expeditiously finalize the proposed regulations so that patients and health care providers can better access and use the data in records to improve the coordination, quality, and safety of care.


Alliance for Better Health Kantara Federated Identity Resilient Ecosystem Work Group
American Academy of Family Physicians Kantara Healthcare Identity Assurance Workgroup
American Medical Informatics Association (AMIA) Manifest MedEx
Apple Microsoft
b.well Missouri Health Connection
CareLoop Inc. National Association of Accountable Care Organizations
Ciitizen  Pacific Business Group on Health
Computational Health Informatics Program and SMART Health IT, Boston Children’s Hospital
Engaging Patient Strategy/LifeWIRE Group Rock Health
Evidation Health, Inc. The ATA for telehealth
Health Care IT Policy Consulting LLC The CARIN Alliance
Hugo Health The NGLY1 Foundation
Humetrix The Pew Charitable Trusts